We are using Compliance One loan processing software (Wolters Kluwer) and are preparing our own Notice to Home Loan Applicant disclsorues. The credit bureau (TransUnion/Kroll Factual) only assigns codes to 4 (not 5) of the "key factors that adversely affected you score". Thus, if there is a fifth reason: "Note: In addition to the factors listed above, the number of inquiries on the consumers credit file has adversely impacted the credit score" (or sometimes it is listed as "FACTA: Inquiries impacted the credit score") since is NOT assigned a code and is therefore not being automatically picked up by Compliance One and dropped into the "Notice to Home Loan Applicant" form that is sent to the applicant(s).
I thought this 5th reason was absolutely REQUIRED to be listed on the Notice to the Home Loan Applicant"?
Management is stating that they will continue to use the automatically populated version of the Notice form as provided for in the Compliance One agreement. Thus, the 5th reason will not be listed when applicable, because there is no code assigned to it by the credit bureau so it can automatically populate the form. Essentiallly, they stated that they are relying on the Wolters Kluver guarantee that their product is correct from a compliance standpoint.
Has anyone had this issue come up during an exam or audit?
Thanks in advance for any responses.